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| The Tax Publishers2020 TaxPub(DT) 5582 (Pune-Trib) INCOME TAX ACT, 1961
Section 92C
VAMA Industrial Ltd. was mainly into Design Engineering Services which were functionally different than Software Development Services Business. Accordingly, there could be no comparability analysis.
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Transfer pricing - Determination of ALP - Selection of comparables - Functional dissimilarity
Assessee rendered software development services to its AE abroad. TPO considered VAMA Industrial Ltd. as comparable to assessee's case. Held: VAMA Industrial Ltd. was mainly into Design Engineering Services which were functionally different than Software Development Services Business. Accordingly, there could be no comparability analysis.
REFERRED :
FAVOUR : In assessee's favour.
A.Y. : 2012-13
INCOME TAX ACT, 1961
Section 92C
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